Separate Concurring Opinion 15 G.R. No. 224469 future and their probable increase, and after distributing to the natives what may be necessary for tillage and pasturage, confirming them in what they now have and giving them more if necessary, all the rest of said lands may remain free and unencumbered for us to dispose of as we may wish. We therefore order and command that all viceroys and presidents of pretorial courts designate at such time as shall to them seem most expedient, a suitable period within which all possessors of tracts, farms, plantations, and estates shall exhibit to them and to the court officers appointed by them for this purpose, their title deeds thereto. And those who are in possession by virtue of proper deeds and receipts, or by virtue of just prescriptive right shall be protected, and all the rest shall be restored to us to be disposed of at our will." 68 (Citations omitted, emphasis in the original) Having exclusive dominion over the lands in the Philippines, the Spanish government began issuing royal grants and concessions which effectively distributed land rights to the Spaniards and loyal Spanish subjects. This notwithstanding, the Law of the Indies, and the subsequent laws enacted by the Spanish government, made it clear that the distribution of land rights and interests should not impair the rights and interests of the natives in their holdings. 69 The Spanish Government's intention to guarantee the rights of the natives over their lands was reiterated and further clarified in the subsequent Royal Decree of October 15, 1754, which stated that the native's "justified long and continuous possession" qualified them for title to their cultivated land. The Royal Decree considered as valid title the native's ancient possession of their land, notwithstanding the possessor's failure to produce title deeds over the land. 70 The Royal Cedula Circular of March 3, 1798 further expounded on this matter and proclaimed that "the will of the 'Crown' as expressed in various, instructions, royal edicts, orders and decrees, that the distribution of land to conquistadores' discoverers, and settlers should never prejudice the natives and their land-holdings." 71 Despite the apRarent deference of the Spanish Government to the native's rights over their lands, subsequent laws, however, triggered their 68 69 70 71 J. Puno, Separate Opinion in Cruz v. Secretary of Natural Resources, 400 Phil. 932, 934-935 (2000) [Per Curiam, En Banc]. Owen James Lynch, Jr., Native Title, Private Right and Tribal Land Law: An Introductory Survey, 57 PHIL. L. J. 268, 274 (I 982). Id. at 274-275. Id. at 275.